Date: 08/22/2000 10:53 AM
Subject: Proposed independence rule
I am providing this comment in hopes it will be considered in the proposed SEC
rule prohibiting non-audit services to CPA firm's attest clients. I am highly
opposed to this proposed rule. My firm serves small SEC registrants that require
considerable hand holding to comply with SEC reporting rules. The rule proposed
by the SEC will effectively eliminate our ability to provide this service; which
is a service that benefits the SEC may I point out, and will limit the ability
of the registrants to comply with the significant requirements imposed by the
SEC. This is a disservice to the SEC, the client and the investing public.
Small registrants cannot afford to hire the expertise necessary to comply with
the many regulations promulgated by the SEC and other regulators. They rely on
their CPA firms to perform not only the audit function but also advise them on
the many systems, controls and policies they must follow in order to be
successful in business and comply with the regulations.
It will be next to impossible for these enterprises to segregate their single
CPA firm relationship into multiple relationships in order to comply with the
new independence rules. Even if this were possible, the total cost to the
registrant would significantly increase, thereby reducing investor value. CPA's
will refuse to provide audit services or require excessive fee increases due to
the inefficiencies imposed by these regulations. Most CPA firms below the Big
Five in size will stop serving SEC registrants, further restricting the access
of smaller companies to reasonably priced audit services.
The SEC has proposed these new rules with no empirical evidence to support its
presumption that the prohibited services compromise independence. To assume our
independence is impared by this matter is highly offensive, and questions the
business ethics of our profession. This proposal also makes it likely that even
the largest audit firms will not be able to retain the specialist non-CPA
experts that are necessary in today's technology driven environment to perform
quality audits of large and small enterprises.
This proposal will surely reduce the quality of audits, limit access to auditing
services and hurt the investing public - this is quite contrary to the interest
the the SEC is supposed to protect.
Don
Don H. Hansen
2707 Colby Ave., Suite 801
Everett, WA 98201-3510